ENVIRONMENTAL

MONITORING

PLAN

for imidacloprid

ASIAN LONGHORNED BEETLE COOPERATIVE ERADICATION PROGRAM

Boston & Worcester, Massachusetts

2011

 

United States 

Department of

Agriculture 

Animal and

Plant Health

Inspection

Service

Plant Protection

and Quarantine

Prepared by the

Environmental 

Compliance Team March 2011 version
2011 Environmental Monitoring Plan 1

General

The United States Department of Agriculture (USDA) - Animal and Plant Health Inspection 

Service (APHIS) Directive 5640.1 (4/19/02) commits the Agency to a policy of fulfilling the 

mandates of the National Environmental Policy Act; the Endangered Species Act; the Federal 

Insecticide, Fungicide, and Rodenticide Act; and other statutes that require monitoring the 

potential effects of Federal programs on the environment. The monitoring described in this 

Environmental Monitoring Plan (EMP) supports these commitments for the Massachusetts Asian 

Longhorned Beetle (ALB) Cooperative Eradication Program.

Environmental sampling for residues of imidacloprid is proposed to validate the assumptions of 

the Environmental Assessments created for the program and to address specific concerns raised 

by the public. Imidacloprid is a systemic insecticide used as a treatment of ALB host trees at 

risk for infestation. ALB host trees may be treated via ground or trunk injection based on the 

size of the tree, local hydrology, and other factors. Targets identified for monitoring include 

groundwater, surface water, and non-target organisms. Monitoring will be conducted to 

determine if ALB Program systemic treatments of host trees result in the movement of 

imidacloprid beyond the immediate treatment area. 

Samples collected as part of this plan will be reported to the ALB Program management in an 

annual report. If any residue samples seem unusually high, ALB Program management will be 

contacted immediately to determine what, if any, action may be needed to adjust Program 

operating procedures. This monitoring plan is a working document and will be updated as 

needed based on new information provided to the Environmental Compliance Team (ECT). It is 

designed to be a reference document for staff that will work with the Environmental Compliance 

Team to collect and document monitoring samples during the ALB eradication program. 

Training will be provided in early 2011 to field staff on implementing this monitoring plan. The 

monitoring described below is for 2011. The EMP will be updated annually.

Human and Environmental Health

Objectives

Monitoring for potential exposure is designed to: 

1. demonstrate the effectiveness of ALB operational procedures in excluding or minimizing 

exposure of the public and the environment to Program-applied imidacloprid;

2. collect data which can be used to evaluate whether the assumptions used in the Environmental 

Assessments are valid estimates of potential exposure of the public and the environment 

to Program-applied imidacloprid; and

3. investigate any Program-related complaints or reports of adverse effects on public health, 

worker safety, environmental quality, or non-target species.

Methods

This document is a reference for ALB program staff and may not address issues that are brought 

to the attention of the program staff at upcoming public meetings and as the program progresses. 

If additional monitoring or new types of monitoring are necessary, please contact Bob Baca at 
2011 Environmental Monitoring Plan 2

301-734-7592 or by email at robert.m.baca@aphis.usda.gov for guidance. APHIS environmental 

monitoring is flexible and easily altered, but discussions will be needed to determine the best 

course of action given the analytical tools available.

Sensitive Site Inventory

The ALB program will identify sensitive sites prior to the initiation of chemical treatments. 

Sensitive sites are areas where the public may be exposed directly to chemicals and areas where 

there are specific concerns about potential impacts due to program activities. The program will 

identify any ground or surface waters used as a source of drinking water in or adjacent to the 

proposed treatment area. Additional sensitive sites may include, but are not limited to, the 

location of apiaries, schools and playgrounds, and vernal pools.

Descriptions and locations of sensitive sites identified by the program will be provided to the 

ECT. It is preferred that these lists be submitted in an electronic form, but they may also be 

submitted as a printed hard copy. Note the name and location of the water, the type of water 

(ground, surface, lake, etc.), and the distance and direction from the nearest treatment area. Prior 

to the start of chemical treatments, provide the list of sensitive sites to the ECT at the following 

address:

Dr. Robert Baca, USDA-APHIS-PPQ, 4700 River Road, Unit 150, Room 5A-04b,

Riverdale, MD 20737 or via email to robert.m.baca@aphis.usda.gov

Minimum Required Sample Sizes

Samples collection procedures are described below, but for easy reference, the following table 

provides the minimum sample sizes required to analyze a single sample type for imidacloprid:

It may be possible to analyze smaller samples, but at best they will be less precise. If the 

minimum sample size is not available, collect as much as possible from the sample location. The 

table above shows the types of samples that the lab can currently analyze. If other types of 

samples are collected, their analysis is not guaranteed and it could take several months for the lab 

to develop a satisfactory analytical method. We do not suggest taking samples beyond those in 

the table, though you may find it necessary in certain situations. Contact the ECT promptly for 

guidance on collection of such samples.

Surface Water samples

Surface water samples will be collected near the shore of ponds, lakes, or reservoirs, with 

priority given to any identified as a source of drinking water. Pre-treatment surface water 

samples should be collected approximately one week prior to the initiation of the spring 2011

Sample Type Minimum Size

Leaves, twigs, bark 50 grams

Soil, sediment 50 grams

Sap, honey 50 ml

Water 4800 ml

Bees 25 bees
2011 Environmental Monitoring Plan 3

programmatic chemical treatments . Additional samples should be collected at these stations

approximately one week following treatments and then approximately one, three, and six months 

later. Care should be exercised to ensure the water samples are free of turbidity and sediment. 

4.8 liters of water will be collected for analysis from each sample station. (For minimum sample 

sizes for all sample types, see the last page of this document.) Following collection, samples will 

be kept on ice, in the dark, and remain chilled until they can be frozen for shipment. For more 

detailed information on sampling procedures, refer to SOP EM-03 Collection of Water Samples,

available at http://www.aphis.usda.gov/plant_health/plant_pest_info/emt/support_docs.shtml. 

Groundwater samples

Groundwater monitoring wells, installed as part of third-party subsurface environmental 

investigations, have been identified in the City of Worcester, and the Towns of Holden, West 

Boylston, and Shrewsbury. However, no treatments are expected at this time at sites near 

groundwater wells, and no sampling of such wells is required. If such samples are found 

necessary, they will be collected from the unconfined aquifer (i.e. water table) at chosen sites

prior to the initiation of the spring 2011 programmatic chemical treatments, approximately one 

week following treatments, one month following treatments, and at two-month intervals 

thereafter.

Each time groundwater samples are collected, the volume of water in each well will be 

determined. If possible three well volumes will be purged and the well will be allowed to 

recharge before collecting the sample for analysis. Samples will be obtained using well bailers, 

peristaltic pumps, or submersible pumps depending on the well location and depth to water. 4.8 

liters of water will be collected for analysis from each well. Following collection, samples will 

be kept on ice, in the dark, and remain chilled until they can be frozen for shipment. For more 

detailed information on sampling procedures, refer to SOP EM-14 Collection of Groundwater

Samples, available at 

http://www.aphis.usda.gov/plant_health/plant_pest_info/emt/support_docs.shtml. 

Leaf Litter Samples

Whenever possible, leaf litter samples (not leaves from treated trees) will be collected each time 

ground- and surface water samples are collected. Leaf litter will be collected around treated trees 

(no conifer needles) near and up-gradient from the monitoring wells. If no leaf litter is available, 

please note that on the 2060 Environmental Monitoring Form for the groundwater sample. Do 

not collect leaves that are on trees if no leaf litter is available. For more detailed information on 

sampling procedures, refer to SOP EM-07 Collection of Vegetation Samples, available at

http://www.aphis.usda.gov/plant_health/plant_pest_info/emt/support_docs.shtml. 

Soil Samples

Whenever possible, soil samples will be collected each time ground- and surface water samples 

are collected. Soil from within about six inches from the surface will be collected around treated 

trees. For more detailed information on sampling procedures, refer to SOP EM06 - Collection of 

Soil Samples, available at 

http://www.aphis.usda.gov/plant_health/plant_pest_info/emt/support_docs.shtml. 
2011 Environmental Monitoring Plan 4

Vernal Pool-Related Samples

Vernal pools represent potential new sample areas in 2011. If vernal pools are identified for 

environmental monitoring, the same sampling techniques above for water, soil, and leaf litter are 

appropriate. Water should be collected from the pool directly, and care should be taken to not 

stir up the sediment (sediment makes the chemical analysis more difficult). Soil samples should 

be taken from the dry pool area at those times of year when water is absent. If water is present, 

soil samples should be taken from the wet soil adjacent to the vernal pool, but no so close as to 

mix up the soil and pool water. Leaf litter samples should also be taken in close proximity to the 

vernal pool.

Bee-Related Samples

The Agricultural Research Service (ARS) of USDA is working cooperatively with APHIS to 

investigate the response of bee hives to imidacloprid treatments in the Worcester area. The ARS 

experiment is very thorough with very sensitive analytical capabilities. Any monitoring 

conducted as part of this plan will be used to supplement the samples collected by ARS, and will 

not seek to duplicate their work. Monitoring of bees and honey is not anticipated in the Boston 

area at this time, but could easily be incorporated into the monitoring scheme as needed.

If safe and practical, the Program should work with local beekeepers to collect bee and honey 

(from the hive) samples. As sampling through time is expected, it is optimal to work with 

beekeepers who will agree to multiple sampling events each year. Preference should be given to 

beekeepers with hives in proximity to treatments, but sampling is encouraged throughout the 

Worcester area. 

Bee and honey samples should be collected from each hive. Samples should be collected prior to 

the start of spring treatments, approximately one week following treatments, one month 

following treatments, and at two-month intervals thereafter. A single sample of bees from a hive 

should comprise 25 or more bees. Healthy bees should be collected whenever practical, placed 

in a foil bag, and frozen prior to shipping (for details, see SOP EM-08 Collection of Insect

Samples). A single honey sample from a hive should be 50 ml, and need only be kept dark prior 

to shipping. Freezing the honey may break the glass sample container.

Monitoring for Incidents or Complaints

Priority sampling will be conducted to investigate incidents of unknown origin involving nontarget species or other unintended environmental or human health impacts possibly associated 

with Program-applied imidacloprid. Information about priority sampling can be found in SOP 

EM-09, Priority (Emergency) Sampling. Collect priority samples as soon as possible after the 

complaint, request, or problem is reported. Contact the ECT at (301) 734-7592 to collaborate on 

a sampling plan, sampling methods, and types of samples to collect in order to optimize the 

investigation. If the incident occurs on a weekend, commence the investigation and sampling 

without delay, and contact the ECT as soon as possible on Monday.

Proper documentation of the incident, investigation, and samples is extremely important. When 

responding to priority incidents, send to the ECT all GPS maps showing the site, location where

samples were collected, the nearest treatment area, and treatment history. Be sure to completely 

fill out all information on the APHIS 2060 forms with each sample. Be sure to provide an 
2011 Environmental Monitoring Plan 5

incident/complaint report to the ECT, along with any other information that you feel will be 

helpful in resolving the incident (i.e. photos, observations at the site, etc.).

Endangered and Threatened Species

There are no federally protected species in the eradication area at this time. Should the 

eradication area expand to areas where protected species become a concern, monitoring may be 

required and this monitoring plan will be updated accordingly. 

Sample Processing

Documentation

Complete a separate APHIS 2060 form for each sample collected. (A blank copy is attached for 

reference. Please only use original 2060 forms supplied by the Gulfport Laboratory for 

documentation.) Instructions for completing the APHIS 2060 forms are on the back of each 

form. All appropriate sections of the form should be completed. Samples should be marked as 

“routine” unless they were collected for a complaint or incident investigation where they should 

be marked as “priority.” For each sample, submit the blue copy of the APHIS 2060 form to the 

Center for Plant Health Science and Technology (CPHST) in Gulfport, Mississippi with the 

sample; the white copy of the form to CPHST in the sample shipping container but separate from 

the sample; and the yellow copy of the form (and any maps, photos, etc.) to the Environmental 

Compliance Team (ECT) in Riverdale, Maryland. The pink copy is retained by the sample 

collector.

Shipment of Samples

Ship all samples using some form of overnight delivery. See SOP EM-17, Packaging and 

Shipping of Samples for details. Do not ship samples using USPS Priority Mail or standard 

ground service with other carriers. Overnight delivery allows the sample to stay frozen. 

Shipping any other way will take no less than two to three days and can ruin the samples. Be 

sure that all samples are frozen (except for honey), shipped in a cooler box (not a regular 

cardboard box), and kept cold during shipment. To keep samples cold, ship samples on ice. Do 

not use dry ice, since it will cause the sample containers to crack or break. Either use “blue ice” 

containers (the reusable plastic containers with the blue liquid/gel inside) or contained regular ice 

(that is, seal the ice in zip-loc bags). Unsealed ice will melt and leak during shipment, causing 

unnecessary concern in transit or when received at the laboratory.

Supplies

Most supplies for monitoring are ordered through the CPHST Gulfport Laboratory, although 

certain supplies are obtained locally. A checklist for ordering supplies is located below. This 

checklist is used by all APHIS pest control programs, and several of the supplies listed do not 

pertain to the ALB Program. The Gulfport Laboratory prefers that supply orders be faxed to 

them using the numbers listed on the checklist rather than leaving a voice message for orders.
2011 Environmental Monitoring Plan 6

Responsibilities

APHIS-PPQ Environmental Compliance staff in Riverdale, Maryland will:

1. Review and interpret field and pesticide residue data from the sample collectors and the 

laboratory. Contact the sample collector for clarification as soon as possible if any field 

data is incomplete or unclear. Notify the Program Director or Manager immediately if

any residue data is unexpectedly high in value.

2. Provide training, clarification, and interpretation on how to implement the Environmental 

Monitoring Plan.

3. Submit a comprehensive interpretive report to the Program Director and the National 

Coordinator within 60 working days of receiving all of the Program’s field data and

sampling results.

APHIS-PPQ Center for Plant Health Science and Technology Laboratory staff in Gulfport, 

Mississippi will:

1. Prepare and ship supplies required for the collection, stabilization, and shipment of 

environmental monitoring samples.

2. Provide training on methods for collecting, handling, preserving, and shipping samples.

3. Respond to requests for additional information by field personnel when special sampling 

requirements occur.

4. Analyze monitoring samples according to standard operating procedures for imidacloprid.

5. Complete analyses and report results on the following schedule:

a. Within 23 working days after receipt, complete analyses of all routine samples and 

send results to the ECT.

b. Within 5 working days after receipt, complete analyses of all priority/emergency 

samples and send results to the ECT.

c. Contact ECT if the projected completion schedules need to be extended due to sample 

load or laboratory instrument problems. 

6. Forward copies of all environmental monitoring forms and any attached documentation to the 

ECT each week via overnight mail.

APHIS-PPQ Field Personnel or Cooperators, will:

1. Ensure that sufficient resources from the Program are allocated for completing the monitoring 

activities described in the Environmental Monitoring Plan (EMP).

2. Follow instructions in the EMP and referenced SOPs to develop a plan for sample collection 

and documentation, including:

a. Collection of the type and number of samples recommended in the EMP.

b. Completion of a separate APHIS 2060 form for each sample that is collected.

c. Providing all the information necessary to document the samples. Send all supporting 

documentation, including a copy of the appropriate APHIS 2060 forms to the ECT. 

Send all samples and appropriate APHIS 2060 forms to the laboratory. Ship all 

samples and supporting documentation in accordance with protocols and procedures.

d. Notification of the laboratory prior to shipping any priority, spill, or unusual (i.e. 

other than water, insect, or vegetation) samples.
Sampling Supply Checklist / Order Form Feb2011 version

Environmental Monitoring Supplies Checklist & Order Form

- use the blank areas to indicate the number of items to take to the field or 

how many of that item being ordered from the Gulfport LaboratoryGeneral Monitoring Supplies

Monitoring plan/SOP’s Obtain from ECT Ice chest and wet or blue ice Obtain locally

Field log notebook Thermometer

Compass Baby wipes

Rain gauge 2060 monitoring forms

Indelible marker 4" x 4" resealable plastic bags

Packing/strapping tape 10” x 10" resealable plastic bags

Styrofoam coolers/mailers 12” x 12" resealable plastic bags

Soil Samples Dye Cards

Soil core sampler (used only for 

sampling at depth)

Oil-sensitive dye cards (50 per 

package)

Hand trowel Water-sensitive dye cards (one set 

of paired cards packaged)

12 x 12 x 1⁄4 inch mesh screen 5' bamboo poles/stakes

10” x 14” foil envelopes Paper/alligator clips

Vegetation/Fish/Insect Samples Tacks

Pruning shears/scissors Tweezers/forceps

10” x 14” foil envelopes Nitrile gloves (box of S,M,L,XL)

Strapping tape Water Samples

Aquatic Sediment Samples Hach dissolved oxygen kit (refills)

Dredge tied to strong rope collapsible cubitainer (gallon size)

Hand trowel collapsible cubitainer (liter size)

3" mesh screen Sodium sulfate (small vials)

10x14” foil envelopes pH paper (0-14 range)

Acid or base (squeeze bottle) Obtain locally
Sampling Supply Checklist / Order Form Feb2011 version

A.R.S.E. (Run-off Sampling) Wipe Samples (malathion only)

Plexiglas cover

2” x 2” sterile cotton pads in a 

resealable plastic bag

8"x 8" mesh screen Metric ruler

Tent pegs/nails Pencil

Funnels attached to caps Disposable gloves (box)

500 ml glass bottles Isopropyl alcohol Obtain locally

4" PVC pipe, 14" long Neat (Pure) Chemical Formulations

Post hole digger Amber glass bottle (2 ounce size) 

(also used for honey samples)

Pea gravel, rocks/bricks Obtain locally Parafilm

Bamboo pole/flagging tape Small mailing tubes

collapsible cubitainer (gallon size) Protective eyewear

Sodium sulfate (small vials) Disposable pipette

pH paper (0-14 range) Pipetting bulb

Acid or base (squeeze bottle) Obtain locally Disposable gloves

NOTE: This list above for each sample group is to remind you of important items for that sampling, but 

some items are useful for all sampling. For example, disposable gloves should be used for all sampling, but 

are especially critical for neat, dye card, and wipe samples.

Program: _________________________________ Requested by: ______________________________ 

Date: _____________________________________ Phone: ____________________________________ 

Address: ____________________________________________________________________________________

____________________________________________________________________________________________

____________________________________________________________________________________________

To order supplies, indicate the quantity of each items needed. Fax or mail a copy of this form to CPHST 

Gulfport Lab at 228-822-3137 or barbara.moffett@usda.gov. If fax machines are not working, leave a 

message with the CPHST Gulfport Lab supplies manager at 228-822-3106. Please realize that it may be 

difficult to completely fill order for large quantities of materials.

This is not an exhaustive supply list...items that are not listed here may be available through CPHST 

Gulfport Lab. Not all supplies listed above are required for all pest control programs.
Front page of APHIS Form 2060, the Environmental Monitoring Form.
Back page of APHIS Form 2060, the Environmental Monitoring Form